G.R. No. B.M. No. 1491; November 28, 2007
ATTY. SILVESTRE H. BELLO III, Complainant, vs. ATTYS. JOSE ANSELMO I. CADIZ and ESTELITA D. CORDERO, Respondents.

FACTS

Atty. Silvestre H. Bello III was elected Governor for the Northern Luzon Region of the Integrated Bar of the Philippines (IBP) on June 4, 2005. Atty. Estelita D. Cordero, who garnered the second-highest votes, filed an election protest, moving for Bello’s disqualification on the ground that he was not a bona fide member of the IBP Isabela Chapter but was still listed with the Davao Chapter. The IBP Board of Governors, with Atty. Jose Anselmo I. Cadiz as National President, subsequently resolved to nullify Bello’s election and proclaim Cordero as Governor-elect. Bello then filed a letter-complaint with the Supreme Court, seeking a temporary restraining order to enjoin the implementation of the Board’s resolution and the holding of further elections, arguing he was unlawfully deprived of his position and the chance to run for National Executive Vice-President.
The respondents contested the complaint. The IBP Board argued it was procedurally infirm and substantively justified, maintaining Bello’s dues were consistently credited to Davao Chapter, proving his lack of valid transfer. Bello countered that his transfer to Isabela in 1995 was legitimate and reflected in the IBP National Law List. During the pendency of the case, Bello was appointed General Manager of the Philippine Reclamation Authority. The Court later required the IBP to report on any changes in the situation of the parties.

ISSUE

Whether the administrative complaint filed by Atty. Bello has been rendered moot and academic.

RULING

Yes, the complaint is dismissed on the ground of mootness. The Supreme Court, in its resolution, noted the manifestation from the IBP National Secretary that the 2007 IBP Elections for Governor of Northern Luzon had already been conducted on April 21, 2007, resulting in the election and proclamation of a new Governor, Atty. Abelardo Estrada, for the term 2007-2009. This subsequent event rendered the core issue of the 2005 election contest academic.
The legal logic is grounded in the principle that courts will not adjudicate moot cases. A case becomes moot when there is no longer any actual controversy between the parties or when the issues have ceased to exist, such that a judicial determination would provide no practical legal effect or enforceable relief. Here, the contested term of office for IBP Governor for Northern Luzon (2005-2007) had expired with the conduct of the 2007 elections and the assumption of a new governor. Therefore, resolving the merits of Bello’s disqualification and the validity of the 2005 proclamation would be an academic exercise with no practical consequence. The Court emphasized it will not indulge in deciding moot questions where no practical relief can be granted to the parties. Consequently, the complaint was dismissed.